DOCUMENTS TO BE PRODUCED

1. Please provide the actual credit card contract upon which your complaint is based on.

2. Please provide a contract, agreement, assignment, or other means of demonstrating that the plaintiff has the authority and was legally entitled to collect on the alleged debt.

3. Please furnish reasonable proof, such as an original, or copies of the assignment agreement or assignment agreements, transferring the alleged contract and/or account in question from (NAME of ORIGINAL CREDITOR OR BANK) over to (NAME COLLECTION AGENCY/DEBT BUYER) to show an assignment has been made and that (NAME OF COLLECTION AGENCY/DEBT BUYER) are the real party in interest.

4. Please provide a copy of the assignment between (NAME OF COLLECTION AGENCY/DEBT BUYER) and (NAME OF ORIGINAL CREDITOR OR BANK).

5. Please provide evidence /proof of Defendant’s alleged debt to Plaintiff, including specifically the alleged contract, between Plaintiff and Defendant or any other instrument constructed solely for the purpose of creating a loan agreement between Plaintiff and Defendant bearing Defendant’s signature and/or please produce the contract that legally requires the defendant to pay the amount entered into complaint.

6. Please provide the original or copy of the account agreement that states interest rate, grace period, finance charge, assignment, and specifically the state laws that the agreement and account are governed plus other important facts.

7. Please provide copies of the amount paid and/or the consideration due for the alleged contract/account.

8. Please provide an itemized account of all transactions mentioned in Interrogatory Number Eighteen (18).

9. Provide the record of assignment that displays the information in Interrogatory No. 22.

10. Please provide all copies of manuals, procedures, and protocols used by Plaintiff regarding communication with ____________________ regarding purchased debt.

11. Please provide evidence of authorization of Plaintiff to do business, create loans, issue or extend credit, collect debts and/or operate in the state where Plaintiff conducts their business.

12. Please provide evidence of authorization of Plaintiff & Attorney to do business, create loans, issue or extend credit, collect debts and/or operate as a financial business in the State of ______.

13. Please provide a document or document(s) that proves you did send Defendant a notification of assignment of the account or assignment of rights.

14. Please attach any and all notices sent to Defendant by Plaintiff in regards to this account demanding payment.

15. Please attach copies of all statements generated while this alleged account was open with Plaintiff.

16. Please attach a complete and accurate history of the interest charged on this alleged account with Plaintiff. Show the exact dates those interest rates changed and list the various rates that were charged during this debt and the exact method of amortization.

17. Please attach any and all notices sent to Defendant by Plaintiff announcing changes in interest, fees or penalties and/or the terms of this alleged debt.

18. Identify each Credit Reporting Agency (credit bureau) to which Plaintiff reported Defendant’s debt and the dates of each such report.

19. Please provide the original dunning letter that was sent to Defendant.

20. Please attach any and all notices sent to Defendant by Plaintiff in regards to account announcing transfer and/or assignment of credit card account from Plaintiff to any collection agency or collection attorney.

21. Please attach a copy of the agreement with Plaintiff that grants ATTORNEY NAME HERE Attorney(s) the authority to collect this alleged debt.




CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was mailed on the __th day of (Month) (Year) to ATTORNEY NAME HERE
WITH THEIR ADDRESS.




_______________________

Defendant